TaxTMI 
TaxTMI 
2021 (5) TMI 439
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.... the above appeals en masse. 3. The grounds of appeal raised by the assessee in ITA No.2744/AHD/2015, for A.Y. 2009-10 is as follows: "1. On the facts and circumstances of the case as well as law on the subject, the learned Commissioner of Income Tax (Appeals) has erred in confirming the action of the Assessing Officer in making addition of Rs. 20,52,475/- u/s.69A of the Act on account of cash deposit in Bank Accounts. 2. It is therefore prayed that above addition made by Assessing Officer and confirmed by CIT(A) may please be deleted. 3. Appellant craves leave to add, alter or delete any ground(s) either before or in the course of hearing of the appeal." 4. The facts of the case which can be stated quite shortly are as follows: The assessee is a Senior Territory Manager who has worked for first ten months of the year with M/s Reliance Life Insurance Co. Ltd. and two months thereafter with M/s Bajaj Alliance Life Insurance Co. Ltd. As per AIR information available with the assessing officer, the assessee has two bank accounts with ICICI Bank, Navsari in which cash of Rs. 26,77,200/- and Rs. 21,71,644/- was deposited during the year. The necessary details of cash deposits in....
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....e including the findings of the ld. CIT(A) and other material brought on record. We note that during the appellate proceedings, the assessee made voluminous submissions before the ld CIT(A), which were sent to the assessing officer for comments in the form of remand report. The counter comments of the assessee were also obtained on the comments given by the assessing officer in the remand report. As the cash deposits were claimed to have been made by various investors by the assessee, the assessing officer dealt with each investor and the necessary counter comments were also given by the assessee. Learned Counsel for the assessee relied on the submissions made before the ld CIT(A), during the appellate proceedings. On the other hand, Learned Departmental Representative (in short "the ld. DR") for the Revenue has primarily reiterated the stand taken by the Assessing Officer, which we have already noted in our earlier para and is not being repeated for the sake of brevity. 7. We note that person wise findings as given by the assessing officer as well as the counter comments on these findings by the assessee were discussed during the appellate proceedings and as well as during the as....
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....3).In respect of Shri Sarasvati D Patel, the assessee submitted following details: (i) Confirmation Letter (vide Pb.97-98), (ii) Premium Collection receipt (Pb.99), (iii) Proposal form (vide Pb.100-104), (iv) Bankers cheque (vide Pb.105), (v) Letter filed before AO (vide Pb.106), (vi) Surrender Statement (vide Pb.107). (4).In respect of Shri Vicky Poddar, the assessee submitted following details: (i) Confirmation Letter (vide Pb.108). (5).In respect of Shri Vanita D Patel, the assessee submitted following details: (i) Confirmation Letter (vide Pb.109), (ii) Premium Collection receipt (vide Pb.110), (iii) Proposal from (vide Pb.111-115), (iv) Election Commission Identity Card (vide Pb.116-117), (v) Bank Statement (vide Pb.118), (vi) Bankers cheque (vide Pb.119). (6).In respect of Shri Anila Ajitrai Patel, the assessee submitted following details: (i) Confirmation Letter (vide Pb.120), (ii) Premium Collection Receipt (vide Pb.121), (iii) Proposal form (vide Pb.122-125), (iv) Bankers cheque (vide Pb.126), (v) Surrender Statement (vide Pb.127). (7).In respect of Ms Savita M Patel, the assessee submitted following details: (i) Confirmation Letter (vide Pb.128), (ii) Pr....
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....tion Letter (vide Pb.212), (ii) Premium collection receipt (vide Pb.213), (iii) Proposal form (vide Pb.214-219), (iv) PAN Card (vide Pb.220), (v) Ration Card by Mamlatdar Surat (vide Pb.221-222), (vi) Banker cheque (vide Pb.223), (vii) Letter filed before AO (vide Pb.224), (viii) Surrender Statement (vide Pb.225). (15).In respect of Kalaben Rameshbhai Patel, the assessee submitted following details: (i) Confirmation Letter (vide Pb.226), (ii) Premium collection receipt (vide Pb.227), (iii) Proposal form (vide Pb.228-233), (iv) PAN Card (vide Pb.234), (v) Ration Card by Mamlatdar Surat (vide Pb.235-237), (vi) Banker cheque (vide Pb.238), (vii) Letter filed before AO (vide Pb.239), (viii) Surrender Statement (vide Pb.240). 10. As noted above, assessee has submitted a plethora of documents to prove the genuineness of the transactions. The assessee is a salaried employee and it is not possible for him to maintain full accounts department for his small business and clients. The assessee was working as a Senior Territory Manager in Reliance Life Insurance Co. Ltd. during the first 10 months of the previous year under appeal. Thereafter, in last two months, he had joined Bajaj Alllia....